Cases
Sarmadi v. Canada, 2017 FCA 131
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Vine Estate v. Canada, 2015 DTC 5063 [at 5880], 2015 FCA 125
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | filing amended return does not nullify previous lack of reasonable care/quaere whether neglect can be vicarious though outside accountants | 528 |
Swirsky v. Canada, 2014 DTC 5037 [at 6723], 2014 FCA 36, aff'g 2013 TCC 73, 2013 DTC 1078 [at 431]
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | no objectively reasonable expectation of taxable dividends | 433 |
| Tax Topics - General Concepts - Purpose/Intention | no objectively reasonable income-producing purpose | 83 |
Palmerino v. MNR, 2013 DTC 5157 [at 6375], 2013 CF 919
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Privacy Act - Paragraph 22(1)(a) | onus on CRA to prove communications were part of criminal investigation | 66 |
Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at 7292], 2012 FCA 214
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 99 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | loan made as investment in mining business | 162 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | interest was bad as settlement proceeds not allocated to it | 212 |
House v. Canada, 2011 DTC 5142 [at 6131], 2011 FCA 234
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | credible oral evidence can be uncorroborated by documents | 90 |
Khan v. The Queen, 2009 DTC 804, 2009 TCC 248 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | 34 |
Canada v. Anchor Pointe Energy Ltd., 2007 DTC 5379, 2007 FCA 188
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | damages to lessor for advance lease repudiation were in lieu of rent | 298 |
Canada v. Loewen, 2004 DTC 6321, 2004 FCA 146
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | 92 |
Canada v. Anchor Pointe Energy Ltd., 2003 DTC 5512, 2003 FCA 294
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(5) | objection does not extend normal reassessment period | 240 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | 152 | |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(5) | 240 |
Capital Vision Inc. v. MNR, 2003 DTC 5054 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | 158 |
Roseland Farms Ltd. v. Canada, 2001 DTC 5392, 2001 FCA 167
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | 83 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 104 |
C W Agencies Inc v. The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 82 |
Coffen v. The Queen, 97 DTC 5552 (Ont. Ct. J. (G.D.))
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) | 28 | |
| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 94 |
Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 55 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 151 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | lease inducement payments currently deductible | 117 |
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | 107 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | interest-free advances to US sub by developer | 33 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | interest-free advances made only re loss protection | 47 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 200 |
CPL Holdings Ltd. v. The Queen, 95 DTC 5253 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) | s. 55(2) did not apply as purpose was creditor-proofing | 153 |
Québec (Communauté urbaine) v. Corp. Notre-Dame de Bon-Secours, 95 DTC 5017, [1994] 3 S.C.R. 3
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 167 |
W. Hanley & Co. Ltd. v. The Queen, 90 DTC 6354 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 131 |
First Fund Genesis Corp. v. The Queen, 90 DTC 6337 (FCTD)
Youngman v. The Queen, 90 DTC 6322 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | benefit reduced by interest-free loan made by shareholder | 259 |
The Queen v. Mattabi Mines Ltd., 89 DTC 5357 (FCTD), aff'd 92 DTC 6252 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(gg) | 75 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 75 |
Grohne v. The Queen, 89 DTC 5220 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | mere fulfillment of contractual obligation | 144 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employee | 30 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(5) | 145 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 62 |
Smith, Kline & French Laboratories Ltd. v. A.G. (Can.), 89 DTC 5205 (FCTD)
Interprovincial Co-operative Ltd. v. The Queen, 87 DTC 5115, [1987] 1 CTC 222 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 135 - Subsection 135(4) - Income of the Taxpayer Attributable to Business Done With Members | 51 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | property acquired only because parent so directed | 90 |
Wise v. The Queen, 86 DTC 6023, [1986] 1 CTC 169 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | deposit | 61 |
The Queen v. Bassani, 85 DTC 5232, [1985] 1 CTC 314 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 195 |
Tony Mele Incorporated v. The Queen, 85 DTC 5196, [1985] 1 CTC 252 (FCTD)
Krassman v. The Queen (1979), 102 D.L.R. (3d) 262 (FCTD)
Farmer Construction Ltd. v. The Queen, 83 DTC 5215, [1983] CTC 198 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Court Act - Subparagraph 46(1)(a)(v) | 71 |
Hillsdale Shopping Centre Ltd. v. The Queen, 81 DTC 5261, [1981] CTC 322 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 55 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options | 86 |
Kit-Win Holdings (1973) Ltd. v. The Queen, 81 DTC 5030, [1981] CTC 43 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Purpose/Intention | 39 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 77 |
The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | right to buy and resell product not a right to use | 200 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | 137 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 11 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "including" enlarges | 99 |
Simpson v. The Queen, 79 DTC 5336 (FCTD)
Tobias v. The Queen, 78 DTC 6028, [1978] CTC 113 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Quality Chekd Dairy Products Association v. MNR, 67 DTC 5303 (Ex Ct)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 167 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 130 |
See Also
Morrison v. The Queen, 2018 TCC 220
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | gift was not vitiated by benefits | 518 |
| Tax Topics - General Concepts - Fair Market Value - Other | Ontario list price of generic pharmaceuticals substantially exceeded their FMV in the international market | 201 |
Agence du revenu du Québec v. Stamatopoulos, 2018 QCCA 474
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 2 - Intermediary | ARQ failed to establish that a named supplier to the taxpayer did not act as a supplier or intermediary | 422 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | burden shifted to ARQ once taxpayer showed that it had business dealings with suppliers named in invoices | 246 |
Custodio v. The Queen, 2018 CCI 47
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(2) - Paragraph 227.1(2)(a) | failure of Crown to tender documents proving the unsatisfied-execution requirement | 285 |
Pellerin v. Agence du revenu du Québec, 2017 QCCA 1339
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | statement of onus embedded in s. 152(8) | 75 |
Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) | offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply | 345 |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | Minister's statement was false | 120 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) | expert's report did not include all the underlying data | 109 |
Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | Minister's authorization should not be set aside too readily as being contrary to law | 317 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) | late designation not permitted/rule-of-thumb method invalidated by s. 6(1)(k) | 189 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | separate personal use kilometers required for each vehicle used in year | 169 |
0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business | storage charges were property income, cf. hotel revenue | 243 |
Bekesinski v. The Queen, 2014 DTC 3604 [at 1169], 2014 TCC 245
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) | appellant, who likely backdated resignation, was plausible enough to demolish assumptions | 94 |
Health Quest Inc v. The Queen, 2014 TCC 211 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part II - 24.1 | insufficient product design evidence | 185 |
Galachiuk v. The Queen, 2014 DTC 1153 [at 3494], 2014 TCC 188
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) | due diligence is available for the first relevant year, not only the second | 242 |
Drouin v. The Queen, 2014 DTC 1016 [at 2564], 2013 TCC 139
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | arrangement looking like Barbados tax shelter was in fact genuine business | 118 |
Dr. Mike Orth Inc. v. The Queen, 2013 DTC 1110 [at 588], 2013 TCC 123 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Poulin v. The Queen, 2013 DTC 1102 [at 545], 2013 TCC 104
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(10) | 149 |
Mignardi v. The Queen, [2013] GSTC 39, 2013 TCC 67 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) | onus on Minister where taxpayer had no financial involvement | 114 |
| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) | failure to monitor other director | 71 |
| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(5) | no constructive resignation | 63 |
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | onus on Minister where taxpayer had no financial involvement | 114 |
Pawlak v. The Queen, 2012 TCC 355 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 296 - Subsection 296(2) | 172 |
Basi v. The Queen, 2012 DTC 1282 [at 3836], 2012 TCC 345
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Brewster v. The Queen, 2012 DTC 1178 [at 3451], 2012 TCC 187 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | consent of counsel binding | 96 |
| Tax Topics - Income Tax Act - Section 169 | 112 | |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | 48 | |
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 113 |
Marshall v. The Queen, 2012 DTC 1068 [at 2815], 2012 TCC 21
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | 142 |
Szollosi Bens v. The Queen, 2011 TCC 240
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 285.1 - Subsection 285.1(16) | 93 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(3) | 93 |
Rail v. The Queen, 2011 DTC 1190 [at 1057], 2011 TCC 130
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Richard A. Kanan Corporation v. The Queen, 2011 DTC 1168 [at 928], 2011 TCC 211 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 287 |
Blais v. The Queen, 2011 DTC 1008 [at 55], 2010 TCC 195 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | partnership cannot deduct salary paid to a partner | 53 |
Husky Oil Limited v. Canada, 2010 DTC 5089 [at 6887], 2010 FCA 125
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) | 184 | |
| Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) | 178 | |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 184 |
4528957 Manitoba Ltd. c. M.R.N., 2009 DTC 1218, 2009 TCC 298
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Douthwright v. The Queen, 2007 DTC 1614, 2007 TCC 560 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) | 314 |
Parker Brothers Textile Mills Limited v. The Queen, 2007 DTC 610, 2007 TCC 74
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(dd) | 117 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 54 |
Cloverdale Paint Inc. v. The Queen, 2007 DTC 243, 2006 TCC 628
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) | 125 |
Hawa v. The Queen, 2007 DTC 28, 2006 TCC 612 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | frequent stock trading | 52 |
Anchor Pointe Energy Ltd v. The Queen, 2006 DTC 3365, 2006 TCC 424
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Crystal Beach Park Limited v. The Queen, 2006 DTC 2845, 2006 TCC 183
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 11 - Paragraph 11(5)(a) | 216 |
Arnold v. The Queen, 2005 DTC 1699, 2005 TCC 725 (Informal Procedure)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Orly Automobiles Inc. v. Canada, 2005 FCA 425
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Borys v. The Queen, 2005 DTC 1069, 2005 TCC 397
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | 104 | |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) | 104 |
Morley v. The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | 36 | |
| Tax Topics - General Concepts - Evidence | 30 | |
| Tax Topics - General Concepts - Fair Market Value - Other | 96 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 175 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) - Paragraph 13(27)(d) | 86 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | non-arm's length terms | 107 |
| Tax Topics - Income Tax Act - Section 96 | start-up activities sufficient to constitute carrying on business in common | 110 |
Holm v. The Queen, 2003 DTC 755 (TCC)
Molson Brewery BC Ltd. v. Canada, [2002] FCJ No. 87 (FCTD)
Shaughnessy v. The Queen, 2002 DTC 1272 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) | 92 | |
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | 93 |
Weisz Rocchi & Scholes v. The Queen, [2001] 2 CTC 2520, 2001 DTC 3705 (TCC)
Hallatt v. The Queen, 2001 DTC 128 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Other | 14 |
Bell v. The Queen, 97 DTC 484 (TCC)
Bowens v. The Queen, 94 DTC 1853 (TCC), aff'd 96 DTC 6128 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 183 |
Graham v. The Queen, 92 DTC 1012 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 | 143 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(10) | 61 |
Brad-Lea Meadows Ltd. v. MNR, 90 DTC 1269 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 143 |